“The (province’s) wetlands polices must be enforceable and should always be enforced without citizens having to appeal to the Ontario Municipal Board.” -Joyce SanSankey, Conservation Director, Niagara Falls Nature Club

An Open Letter to the Ontario Ministry of Natural Resources and Forestry from the Niagara Falls Nature Club

(The letter is being posted on Niagara At Large with the permission of Niagara Falls Nature Club conservation director Joyce Sankey.)

Posted November 19th, 2016 on Niagara At Large

To Terese McIntosh, Biodiversity and Wetlands Program and Policy Advisor , Ontario Ministry of Natural Resources and Forestry Policy Division

Dear Ms. McIntosh:

Members of the Niagara Falls Nature Club have been extremely concerned about the many threats to our wetlands.

The Niagara Falls Slough Forest, also known as Thundering Waters, has been sold to a foreign investor for a residential development.

Niagara has a large supply of developable land and an oversupply of housing. Niagara also has many brownfield areas and vacant cleared areas. Bulldozing parts of a swamp forest complex for this development is unnecessary and wrong.

Although the investor claims that she would protect the provincially significant wetlands (PSWs), she plans to isolate them by building roads and bike trails and she plans to build very densely on the site which will, in time, degrade the wetlands.

Ontario now has the opportunity to make policy to protect our wetlands.

The province should work with municipalities to educate them to the importance of preserving wetlands and ensure wetland protection is a part of municipal plans.

Some of the wetlands in the sprawling Thundering Waters Forest area in Niagara Falls – targeted for development

As many municipalities are more focused on encouraging development than on the environment, if municipal wetland policy is weaker than provincial policy, the stronger lever of protection must prevail.

The wetlands polices must be enforceable and should always be enforced without citizens having to appeal to the Ontario Municipal Board.

Biodiversity offsetting was proposed by the Niagara Peninsula Conservation Authority last year. There was no mention of following the mitigation/hierarchy protocol. Most of Niagara’s wetlands are forested swamps. This type of wetland has not been successfully re-created. The science of recreating complex wetlands is not yet advanced and many trials have ended in failure. Offsetting would lead to the death of many species, including species at risk. The focus should be on protecting our wetlands and perhaps enhancing some wetlands, not destroying them with promises of no net loss and conservation banking.

In areas such as Niagara, where we have lost 85% of our wetlands, locally and regionally significant wetlands should be protected and enhanced. Areas surrounding wetlands must be protected as they buffer wetlands and provide habitat for many species which need wetlands and uplands to complete their life cycle.

Urban wetlands need extra care to ensure that residents get a chance to experience all the benefits that being in nature can give them. Ecosystem benefits such as cleaner water and air and flood control are of vital importance in our cities and towns.

Infrastructure building should be prohibited in PSWs.

Please keep the Ontario Wetland Evaluation System criteria strong. Wetland Mapping should be completed in southern Ontario within a few years, especially in areas where wetlands are threatened by development. This mapping should be done by the MNRF and not by local conservation authorities who too often wish to expedite approval for development.

Here in Niagara, I have recently had the privilege of learning about First Nation views of the importance of our natural heritage. Indigenous knowledge and values should be a key part of Ontario’s wetland policy.

Ontario’s wetland policy must have strong language and clear timelines. The government needs to back up its policy with funds committed to oversee and to implement this policy.

Thank you for the opportunity to comment on this policy which hopefully will help to make Ontario a wonderful place with ample ecosystem services for generations to come.

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